General Tax Consultancy
Although tax laws are initially seen as a type of legislation imposing financial obligations, they also encompass many deductions, exemptions, and reliefs. There is a carefully navigated path to take advantage of these opportunities that provide financial ease to businesses. All enterprises aim to achieve maximum compliance with tax laws, minimize tax risks, and make the most of legal opportunities and advantages.
It is particularly important to obtain the right tax consultancy services for exceptional transactions such as businesses entering new investments, disposing of real estate, and company transfers, divisions, and mergers.
Tax Exemptions, Reliefs, and Deductions
Both in terms of corporate tax and VAT, numerous regulations are introduced into our tax legislation every year. It is observed that taxpayers do not fully benefit from, or incorrectly utilize, many provisions such as investment allowances, tax deductions for foreign services, manufacturer and exporter deductions, and tax compliance deductions. Negligence and oversight in these matters can result in additional liabilities such as taxes, penalties, and interest for late payments.
In addition to permanent legal provisions, temporary clauses are also enacted. It is necessary to consolidate the various exemptions and reliefs scattered across different regulations, taking into account practical examples. We are here to ensure that tax deductions, exemptions, and reliefs are applied accurately and without error.
Tax Planning and Restructuring
It is crucial to design the tax structure correctly and accurately calculate tax liabilities to determine the return on investment, especially when entering a new sector. Often, the timing of decisions and implementation methods can lead to unexpected tax advantages or burdens.
Transfer Pricing
When intra-group transactions are conducted in a manner inconsistent with the arm's length principle, both internationally and domestically, resulting in tax loss, it is referred to as transfer pricing. Tax audit units frequently scrutinize such practices. Therefore, transfer pricing is a prominent issue that requires close monitoring of not only national legislation but also OECD regulations, making it one of the most discussed topics of the past decade. This subject, where definitive high court decisions have not yet been established, involves ambiguous and secret comparables that can easily be criticized for tax purposes, presenting a thorny path that certain sectors and groups cannot avoid.
In new structures, it may be necessary to consider transfer pricing provisions and sign advance pricing agreements (APA) with the Revenue Administration. Within this framework, taxpayers within certain limits are required to prepare Transfer Pricing reports and complete a special form to be attached to their corporate tax returns. We support you with our extensive experience both during tax audits and litigation processes in this area.
International Taxation
In today's global economy, it is insufficient to consider the tax burden only on a country-specific basis. Both for capital coming into Turkey and for capital going abroad, it is essential to analyze the tax conditions of different countries thoroughly. Thanks to double taxation avoidance agreements, investing in some countries and transferring money and capital have become much more advantageous. Knowledge in this area is critical, as it can influence the location and scale of investment decisions. We provide consultancy services for investments both within the country and abroad within this scope.
Private Ruling Requests
The impact of private rulings (advance tax rulings), which answer taxpayers' questions to guide their applications, has increased. Reports cannot be written contrary to a private ruling, nor can penalties be imposed. Therefore, it is essential to determine if there is a previously issued opinion on a particular matter and to consider what kind of response might be received if a new opinion is requested. The taxpayer's request letter has significant influence in cases of adverse opinions. To receive a favorable response, the private ruling request letter must be accurately drafted.
Tax Audit Consultancy
One of the processes to be managed during tax audits is the submission of the requested information and documents to the audit officer and maintaining proper communication with them. By examining the requested documents, the likely direction of the audit process can be predicted, and potential criticisms based on the documented matters can be identified. Therefore, the process of signing the minutes is extremely important. It can be challenging to remedy the effects of a hastily signed minute. During this process, it is also essential to file objections with the report reading committee and request settlements. The taxpayer's rights and claims should be asserted without harming the audit process.
